jilijl Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how jilijl ("jilijl," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of individuals ("you," "Player," or "User") who access or use the jilijl online gaming platform available at jilijl.org and any associated applications or services (collectively, the "Platform").

jilijl is committed to protecting the privacy and personal data of all its users in accordance with the Republic Act No. 10173, known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC") of the Philippines.

By registering an account on jilijl or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the Platform.

This Policy should be read together with jilijl's Terms and Conditions and Responsible Gaming Policy, both of which are available on the Platform.

2. Data Controller

jilijl acts as the data controller in respect of the personal data collected through the Platform. As data controller, jilijl determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data protection law.

If you have any questions about how jilijl processes your personal data, or if you wish to exercise any of your data subject rights, you may contact our Data Protection Officer ("DPO") at [email protected]. Please include "Data Privacy" in the subject line of your email to ensure your inquiry is directed to the appropriate team.

3. Data We Collect

jilijl collects the following categories of personal data:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification number (e.g., PhilSys National ID, passport number, or driver's license number).
• Contact Data: Residential address (including city, province, and postal code), email address, and mobile phone number.
• Financial Data: GCash or PayMaya account details, bank account information (for bank transfer transactions), transaction history, deposit and withdrawal records, and account balance information.
• KYC Verification Data: Copies of government-issued identification documents and selfie photographs submitted for identity verification purposes.
• Account Data: Username, encrypted password, account preferences, responsible gaming settings, and communication preferences.
• Gaming Data: Game history, wagering activity, session duration, game preferences, bonus usage, and win/loss records.
• Technical Data: IP address, device type and identifier, browser type and version, operating system, referring URLs, and pages visited on the Platform.
• Communications Data: Records of your communications with jilijl's customer support team, including live chat transcripts and email correspondence.

jilijl does not intentionally collect sensitive personal information beyond what is required for KYC compliance and responsible gaming purposes. Where sensitive information is collected (such as identification documents), it is handled with heightened security measures.

4. How We Collect Your Data

jilijl collects your personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, log files, and similar tracking technologies.
• Third-Party Sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud and compliance service providers; payment data from GCash, PayMaya, and banking partners in connection with your transactions.

5. How We Use Your Data

jilijl uses your personal data for the following purposes:

• To create, manage, and maintain your jilijl account.
• To verify your identity and age (21+) in compliance with PAGCOR requirements and Philippine law.
• To process deposits, withdrawals, and other financial transactions.
• To provide customer support and respond to your inquiries and complaints.
• To administer bonuses, promotions, and loyalty programs.
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities.
• To comply with our legal and regulatory obligations, including reporting requirements under the Anti-Money Laundering Act (AMLA) and PAGCOR regulations.
• To enforce our Terms and Conditions and other Platform policies.
• To send you service-related communications, including account notifications, security alerts, and policy updates.
• To send you marketing communications about jilijl promotions and new features, where you have provided consent or where we have a legitimate interest to do so.
• To analyze Platform usage and improve the jilijl user experience.
• To operate responsible gaming tools, including monitoring for signs of problem gambling and enforcing self-exclusion requests.

6. Legal Basis for Processing

jilijl processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform our contract with you, including account management, transaction processing, and customer support.
• Legal Obligation: Processing necessary to comply with applicable Philippine law, including AMLA reporting, PAGCOR regulatory requirements, and NPC obligations.
• Legitimate Interests: Processing for fraud prevention, Platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing Your Data

jilijl does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment Processors: GCash, PayMaya, and Philippine banking partners, to facilitate deposits and withdrawals.
• KYC & Compliance Providers: Third-party identity verification and anti-money laundering service providers engaged to assist with regulatory compliance.
• IT & Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers who process data on our behalf under strict data processing agreements.
• Customer Support Platforms: Third-party live chat and helpdesk software providers used to deliver customer support services.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law or court order.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required in connection with the investigation or prosecution of criminal activity.

All third-party service providers engaged by jilijl are required to implement appropriate technical and organizational security measures and to process personal data only in accordance with jilijl's instructions and applicable Philippine data protection law.

jilijl does not transfer your personal data outside the Philippines except where required by law or where adequate data protection safeguards are in place.

8. Cookies & Tracking Technologies

jilijl uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function, including session management, authentication, and security. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and responsible gaming configurations, to provide a personalized experience.
• Analytics Cookies: Collect aggregated, anonymized data about how players use the Platform to help us understand usage patterns and improve our services.
• Marketing Cookies: Used to deliver relevant jilijl promotions and measure the effectiveness of our marketing campaigns. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Withdrawing consent for non-essential cookies will not affect your ability to use core Platform features.

9. Data Security

jilijl implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including financial information and identification documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing conducted by independent security professionals.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, jilijl will notify the NPC within 72 hours of becoming aware of the breach and will notify affected players without undue delay, in accordance with the DPA and NPC Circular No. 16-03.

While jilijl takes all reasonable precautions to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your jilijl account credentials and for notifying us immediately if you suspect unauthorized access.

10. Data Retention

jilijl retains your personal data for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable Philippine law. The following retention periods apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AMLA record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by AMLA and PAGCOR regulations.
• KYC Documents: Retained for a minimum of five (5) years after the end of the business relationship, in accordance with AMLA obligations.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years thereafter as evidence of consent.

Upon expiry of the applicable retention period, jilijl will securely delete or anonymize your personal data in accordance with its data disposal procedures.

11. Your Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by jilijl:

• Right to be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right of Access: The right to request a copy of the personal data jilijl holds about you and information about how it is processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your jilijl account settings.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to jilijl's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe jilijl has violated your data privacy rights.

To exercise any of these rights, please contact jilijl's Data Protection Officer at [email protected] with the subject line "Data Privacy Request." jilijl will respond to your request within thirty (30) days. We may need to verify your identity before processing your request.

12. Children's Privacy

The jilijl Platform is strictly intended for individuals who are at least 21 years of age, as required under Philippine law and PAGCOR's regulatory framework. jilijl does not knowingly collect personal data from individuals under the age of 21.

If jilijl becomes aware that it has inadvertently collected personal data from a person under 21, it will take immediate steps to delete that data and close the associated account. If you believe that jilijl may have collected data from an underage individual, please contact us immediately at [email protected].

13. Changes to This Policy

jilijl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, jilijl will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is indicated at the top of this page. Your continued use of the jilijl Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically.

14. Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or jilijl's data practices, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: Data Privacy — [Your Concern]
• Response Time: Within 30 days of receipt of your request

If you are not satisfied with jilijl's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official website.